Introduction
Last updated June 25, 2019
THOMMEN AIRCRAFT EQUIPMENT AG (“Company”, “our”, “us”, or “we”),the “data controller” of the personal information we collect about you pursuant to this Privacy Statement, is committed to protecting your privacy. This Privacy Statement details the steps we take to protect your personal information when you visit our website or applications that contain a link to this Privacy Statement (collectively, our “Website”) or when you contact us. It describes how we process personal information relating to you, including the types of personal information that we collect, the purposes for which we use it, the types of third parties with which we share it, and any rights you may have with respect to such information. Personal information is information, or a combination of pieces of information, that allow you to be identified.
This Privacy Statement applies only when you visit the website www.thommen.aero that link to this Privacy Statement or when you contact us, for example, with a comment, inquiry or customer support request. Personal information collected about you will not be transferred to third parties. It is important that you read this Privacy Statement together with any other privacy statements or other notices we may provide to you on specific occasions when we are collecting or processing your personal information so that you are fully aware of how and why we are using your information.
By using or accessing our Website or contacting us you agree that we may process your personal information in the manner described in this Privacy Statement. Your use of our Website and any information you provide through them is subject at all times to this Privacy Statement and the applicable terms and conditions that apply to the Website.
Important notice for residents of the European economic area (EEA): EEA residents may be entitled to object to certain types of processing activities involving your personal information described in this privacy statement, including where we are relying on a legitimate interest to process your personal information or where we are processing your personal information for direct marketing. in some cases, we may demonstrate that we have compelling legitimate grounds to continue to process your personal information in which case we are not obliged to comply with your request
Please refer to:
1) Our collection of information
2) Our use of information
3) The legal basis on which we process information
4) Anonymizing information
5) How long we keep information
6) Disclosure of information
7) International transfers
8) Security
9) Cookies
10) Do not Track
11) Your rights
12) Links to other website
13) Contact us
1) Our collection of information
a) Information collected directly from you. When you visit our website, we may ask you for personal information to provide a service or carry out a transaction that you have requested. You may also provide personal information to us when you contact us (e.g., with a comment, inquiry or customer support request) or register for an account to use our services.
The personal information we collect from you when you use our website may include:
Identity data, such as your name, title, company/organization name, e-mail address, telephone and fax numbers and physical address (including street, city, state, postal code, and/or country);
Registration data, such as information provided by you when you register for an account to use our website, including user names and passwords;
Recruitment data, including information submitted in connection with a job application or inquiry (as described below);
Marketing and communications data, including your marketing preferences and your subscriptions to our publications;
We will use your personal information to send you newsletters, offers or other marketing emails that keep you up to date with news, events, products and research opportunities, from THOMMEN that may be of interest. Depending on the nature of your interaction with us and the lasws of the country where you live, you may have actively given us your consent for this, by opting in, or we mai be entitled to rely on your implied consent or our legitimate interests. The opportunity to opt out of future marketing emails will always be provided, and information on how to do this given when your personal information is collected and on every marketing email sent.
Financial information, including credit card or other financial account information for the purpose of enabling us to facilitate your purchase of company products and services that may be available on our website.
Export control information, such as your nationality, citizenship and country of residence, that allows us to determine your eligibility under export control regulations to receive information about certain technologies;
Transaction data, including inquiries about and orders for our products and services and details of payments to and from you;
Your feedback, including feedback from you about our services regarding customer surveys as well as our products and services generally.
When you do not provide requested information, we may not be able to provide you the requested service or complete your transaction.
b) Information we collect about you. We collect certain information about your visit to our website, including:
Usage data, including information about how you use our website, what pages you view, the number of bytes transferred, the links you click, the materials you access, the date and time you access the Site, the website from which you linked to one of our Website and other actions taken within the Website; and
Technical data, such as your Internet Protocol (IP) address, your browser type and capabilities and language and your operating system.
For information about the cookies we use on our Website, please refer to the section entitled “Cookies” below.
c) Geo-location information. For certain Website, with your express consent, we may collect the precise, real-time location (i.e., geo-location) of your mobile device. This information will be used only for purposes of facilitating your use of the website. The geo-location of your mobile device may be disclosed to our service providers who may process this information in connection with providing services on our behalf. Once you have consented to the collection of the precise, real-time location of your mobile device, you may adjust this consent by managing your Location Services preferences through the settings of your mobile device.
d) Information collected from third parties. In accordance with applicable law, we may collect personal information about you from third parties, such as social media website/applications, which we may combine with the information we already hold about you in order to help us improve and customize our Website to your preferences and for other purposes set forth in this Privacy Statement.
2) Our use of information
We may use the personal information collected via our website or when you contact us for purposes that include:
Services and transactions. We may use your personal information to deliver services to you or carry out transactions you have requested, including, but not limited to, providing information on Company products or services you have purchased or otherwise use, registering purchased products, processing product orders, handling warranty claims, replacing product manuals, answering customer service requests and facilitating the use of our Website.
Administering and protecting our business and website. We may use your personal information to administer and protect our business and our website, including troubleshooting, system maintenance, support, reporting and hosting of data.
Improving our business, website, products and services. We may use your personal information to perform business analyses or for other purposes that help us to develop and improve the quality of our business, Website, products and services (including new products and services), for example, by customizing our Website to your particular preferences or interests.
In accordance with applicable laws and regulations, we may use your personal information to inform you of products or services which may be of interest to you, and to otherwise communicate with you about offerings, events and news, surveys, special offers, and related topics. You are able to opt-out from marketing communications sent via e-mail at any time, free of charge by using the “unsubscribe” link in any e-mail marketing materials you receive from us, or by contacting us using the contact information listed in this Privacy Statement. Depending on your country of residence, you may also be able to opt out of other types of marketing communications; please contact us using the contact information listed in the Privacy Statement for more information.
Employment applications. In connection with a job application or inquiry, you may provide us with information about yourself, such as a resume/curriculum vitae, professional references, information about education and job background, and information about professional training and certifications. Our management board, the respective supervisor and our HR department may use this information for the purpose of employment consideration, and as otherwise set forth in any separate privacy statement or other notice made available to in connection with your application.
Research and analysis. We may use your personal information to conduct research and analysis to help us analyze your purchasing preferences, identify the products and services that best meet your requirements and measure the effectiveness of the advertising we serve you.
Enforcement: We may use the personal information we collect in order to detect, prevent and respond to fraud, intellectual property infringement, violations of our terms and conditions, violations of law or other misuse of our website.
Where permitted by law, we may combine the information that we collect via our Website with other information we hold about you (such as information about your use of our products and services) in order to offer you an improved and consistent customer experience when interacting with us or for other purposes set forth in this Privacy Statement.
3) The legal basis on which we process information
Where required by law, we will ensure there is a legal basis for the processing of your personal information. In most cases the legal basis will be that:
the processing is necessary for the performance of the services we provide to you;
the processing is necessary to comply with our legal obligations, including compliance with applicable laws, regulations, governmental and quasi-governmental requests, court orders or subpoenas;
the processing is based on your consent to the processing of your personal information for one or more specified purposes (e.g. marketing); or
the processing is necessary to meet our legitimate interests, for example to develop and improve our Website, products and/or services for the benefit of our customers.
4) Anonymizing Information
In accordance with applicable law, we may anonymize your personal information so that it can no longer be used to identify you. Anonymized information is not considered personal information and is therefore not subject to this Privacy Statement. We may collect, use and share anonymized information for any purpose.
5) How long we keep information
The period during which we store your personal information varies depending on the purpose for the processing. For example, we store personal information needed to provide you with products and services, or to facilitate transactions you have requested, for so long as you are a customer of the Company. We store your personal information for marketing purposes until you have opted out of receiving further direct marketing communications in accordance with applicable law. If you submit an employment application via our Website, we will retain details of your application as set forth in the privacy statement or other notice made available to you in connection with your application or as otherwise required by law. In all other cases, we store your personal information for as long as is needed to fulfill the purposes outlined in this privacy statement, following which time it is either anonymized (where permitted by applicable law), deleted or destroyed.
6) Disclosure of Information
We may share your personal information with selected third parties in accordance with applicable law, including as set out below.
Distributors and other trusted business partners. We may share your personal information with third parties that distribute our products and other trusted business partners for purposes that include allowing those third parties to send marketing communications to you. Such sharing of personal information for marketing purposes will be performed in accordance with applicable laws and regulations.
Disclosure in connection with transactions. In connection with certain transactions, we may disclose some or all of your personal information to financial institutions, government entities and shipping companies or postal services involved in fulfillment of the transaction.
Disclosures in connection with acquisitions or divestitures. Circumstances may arise where for strategic or other business reasons the Company decides to sell, buy, divest, merge or otherwise reorganize businesses in some countries. We may disclose information we maintain about you to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, divestiture or sale of all or a portion of the Company’s assets.
Disclosure for other reasons. We may disclose personal information if required or authorized to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements or with legal process served on us, to protect and defend our rights or property or, in urgent circumstances, to protect the personal safety of any individual.
7) International transfers
We are a global company. By using or accessing our Website or contacting us and giving your information to us, you acknowledge and agree that your personal information may be collected in, transferred to and accessed by the Company, suppliers, distributors and other business partners and/or agents located in countries outside of your country or residence, in accordance with applicable law. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country of residence. However, we will take reasonable steps to protect your privacy and to provide a level of protection of personal information that is comparable to that of your country of residence.
Users Located in the European Economic Area (EEA)
Where required, we have put in place appropriate safeguards with our contractors, distributors and other business partners and agents to ensure that transfers of personal information outside the EEA are adequately protected. These safeguards typically comprise the EU Standard Contractual Clauses in accordance with Article 46(2) of the EU General Data Protection Regulation. For more information on the appropriate safeguards in place to protect your personal information, please contact us using the details at the end of this Privacy Statement.
8) Security
We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure, including implementation of such security measures as may be required by applicable law.However, no information system can be 100% secure, so we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information you transmit to the Website over networks that we do not control, including the Internet and wireless networks.
The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a User ID and password to access the Website, you are responsible for keeping those log-on credentials confidential and not revealing them to others.
9) Cookies and similar technologies
What is a cookie?
Cookies are text files containing small amounts of information which is downloaded to your hard disk or to your browser’s memory when you visit one of our Website. Cookies are useful because they help arrange the content and layout of our Website and allow us to recognize those computers or other devices that have been to our Website before. Cookies do many different jobs, such as allowing our Website to remember your preference settings and helping us to enhance the usability and performance of our Website and your experience using them.
Our Website also may contain electronic images known as web beacons – sometimes called single-pixel gifs – that allow us to count the number of users who have visited specific pages. We may include web beacons in promotional e-mail messages or newsletters in order to determine whether messages have been opened and acted upon.
Categories of cookies and similar technologies that we use
The type of cookie or similar technology that may be used on our Website can be put into 1 of 4 categories: Strictly Necessary, Performance, Functionality & Profile and Advertising.
Strictly Necessary Cookies
These cookies are essential, as they enable you to move around our Website and use their features, particularly in connection with information searches and order placement. Without these cookies, services you have asked for cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet. An example of a strictly necessary cookie is a “shopping basket cookie,” which is used to remember the products that you wish to purchase when you add products to your shopping basket or proceed to checkout.
Performance Cookies
These cookies collect information about how you use our Website, for example which pages you go to most often and if you get any error messages from certain pages. These cookies collect information that is used to improve how our Website work. Without these cookies we cannot learn how our Website are performing and make relevant improvements that could better your browsing experience. Examples of performance cookies that our Website use include Google and Adobe Analytics (see further discussion below).
Functionality & Profile Cookies
These cookies allow our Website to store information that you provide such as your site language preferences and to store technical information useful for your interactions with our Website. For instance, they remember your user ID and elements of your user profile. They also ensure that your experience using the Website and our marketing efforts are relevant to you. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. These cookies will not be used to track your browsing activity on other website.
Advertising Cookies and Similar Technologies
These cookies or similar technologies may be used to deliver advertisements that are more relevant to you and your interests. They may also be used to limit the times you see an advertisement as well as help to measure the effectiveness of the advertising campaign. These cookies may track your visits to other website. Without these cookies or other technologies, online advertisements you encounter will be less relevant to you and your interests.
We permit third-party advertising partners to use cookies and other technologies to collect information about your browsing activities over time and across different website when you use our website, including products that you browse or purchase and your location. An example of advertising cookies is Google AdWords.
Setting your cookie preference:
You may be asked to consent to our use of cookies as described in this Privacy Statement by way of a cookie information banner upon your first use of our Website. You can usually modify your browser settings to decline cookies and you can withdraw your consent at any time by modifying the settings of your browser to reject or disable cookies. If you choose to decline cookies, you may not be able to fully experience the features of the Website or other website that you visit.
Our use of web analytics:
We use industry standard web analytics to track visits to our website. These analytics are provided by Google Analytics, (“Web Analytics Provider”). The information generated by the cookie about your use of our Website (including your IP address) will be transmitted to and stored by our Web Analytic Providers on their servers. The Web Analytics Providers will use this information for the purpose of evaluating your use of our Website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The Web Analytics Providers may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf.
You may opt out of Google, web analytics or otherwise control how these technologies are used when you visit our website, by following the instructions at the bottom of the page.
10) Do Not Track
Some web browsers may transmit “do-not-track” signals to the Website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
11) Your rights
You may have certain rights with respect to personal information about you that is collected through the Website or when you contact us. If you are a resident of the EEA, the rights described below may apply to you. For other users, the rights that apply to you will depend on the laws of your country of residence. We will facilitate your exercise of the rights that apply to you in accordance with applicable law. For more information about your rights, please contact us using the contact details at the end of this Privacy Statement.
Access : You may have the right to access, review and correct personal information collected through our Website or when you contact us. In some cases, you can do this by going to the page on which you provided the information. You can help us to maintain the accuracy of your information by notifying us of any change to your mailing address, phone number or e-mail address.
Object : You may be entitled to object to certain types of processing activities involving your personal information, including where we are relying on a legitimate interest to process your personal information or where we are processing your personal information for direct marketing. in some cases, we may demonstrate that we have compelling legitimate grounds to continue to process your personal information in which case we are not obliged to comply with your request.
Erasure : You may be entitled to request the erasure of your personal information, for example, where the information is no longer necessary for the purposes for which they were collected.
Restriction : You may be entitled to request that we restrict our processing of your personal information, for example, where the accuracy of the information is contested by you.
Data portability : You may be entitled to receive and reuse your personal information for your own purposes. This is known as the right to data portability and, where applicable, requires us to move, copy or transfer your personal information from our systems to you or (where technically feasible) a third party chosen by you without affecting its usability.
Consent: If you have provided your consent to the processing of your personal information, you may have the right to withdraw your consent at any time by contacting us using the contact details at the end of this Privacy Statement or, in the case of email marketing, by using the “unsubscribe” link in any of our marketing emails. This won’t affect the lawfulness of any processing up to that point.
We will respond to any requests from you to exercise your rights within the timeframes required by law. To exercise any of your rights, please contact us using the contact details set out at the end of this Privacy Statement. We may take steps to verify your identity before taking action on a request.
12) Links to other website
Our Website may contain links to third-party website, products and services. We have no liability or responsibility for those website, products and services, their policies, or their collection or other processing of your personal information. The practices of those third parties with respect to information collected through their website, products or services is governed by their own privacy policies. We encourage you to learn about the privacy policies of those third parties.
13) Contact us
If you have questions regarding this Privacy Statement or our handling of your personal information, would like to lodge a complaint, or wish to contact our Data Protection Officer, please contact us using the contact information listed below. We will promptly address your concern and strive to reach a satisfactory resolution.
Email: info@thommen.aero
Mailing Address: THOMMEN AIRCRAFT EQUIPMENT AG
Hofackerstrasse 48
4132 Muttenz
Switzerland
Change to this Privacy Statement:
We may occasionally update this Privacy Statement. When we do, we will revise the “last updated” date at the top and bottom of the Privacy Statement and take such additional steps as may be required by law.
Last updated June 25, 2019.